Dyer v. Howell’s Empirical Analysis
1971
Citation profile
39 state decisions
How this case has been cited
Cited by 39 later decisions — most recently September 2015 · most notably 3 Va. App. 15 - Martin v. Pittsylvania County Department of Social Services (1986), Malpass v. Morgan (1972)
39 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Judd v. Van Horn · Forbes v. Haney
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“From ... the ... evidence before the court, it is clear that the one thing for which the welfare of [the child] cries out is permanent stability in proper surroundings. It is problematical that [the child] could get that stability in [the natural father’s] home. She can get it in the [adoptive parents’] home. To deny the adoption by the [child’s maternal aunt and uncle] now, against the possibility that [the father] might at some unknown time in the future be able to prove himself entitled to a change of custody, would be to deny [the child] contrary to her best interests, the security and stability she so desperately needs.”
1 later decision quote this exact passage · from the majority““For Dyer to be entitled to a later change of custody, the burden was upon him to show that circumstances had so changed that it would be in Kathy’s best interests to transfer her custody to him. Thus, the rule of decision in this case is that the welfare of the child is the paramount consideration.” 212 Va. at 456 , 184 S.E.2d at 792 .”
1 later decision quote this exact passage · from the majoritye.g. McEntire v. Redfearn“In so holding, we have not overlooked the expressed and obviously sincere desire of the father to have the child with him or his claimed right as the natural parent, which in different circumstances we would respect, to be awarded her custody.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.